CP-201500850, Fifth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

Fifth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML15253A372
Person / Time
Site:	Comanche Peak
Issue date:	08/27/2015
From:	Flores R, Thomas McCool Luminant Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-201500850, EA-12-049, TAC MF0860, TAC MF0861
Download: ML15253A372 (9)

Text

Rafael Flores Luminant Power Senior Vice President P 0 Box 1002

& Chief Nuclear Officer 6322 North FM 56 Luminant rafael.flores@luminant.com Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-201500850 REF 10 CFR 2.202 Log # TXX-15124 August 27, 2015 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

SUBJECT:

Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 AND 50-446, Fifth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049) (TAC NOS. MF0860 and MF0861)

REFERENCES:

1. NRC Order Number\EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events dated March 12, 2012

2. NRC Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0,. dated August 29, 2012

3. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Luminant Generation Company LLC's Letter TXX-12158, Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External events (Order Number EA-12-049), dated October 25, 2012

5. Luminant Generation Company LLC's Letter TXX-13030, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation strategies for Beyond-Design-Basis External events (Order Number EA-12-049), dated February 28, 2013

Dear Sir or Madam:

On March 12,, 2012, the Nuclear Regulatory Commission (NRC) staff issued an order (Reference 1) to Luminant Generation Company LLC (Luminant Power). Reference 1 was immediately effective and directs Luminant to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in Attachment 2 of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, ju L~

U. S. Nuclear Regulatory Commission TXX-15 124 Page 2 of 2 08/27/20 15 Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision 0 (Reference

3) with clarifications and exceptions identified in Reference 2. Reference 4 provided Luminant Power's initial status report regarding mitigation strategies. Reference 5 provided Luminant Power's overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. The purpose of this letter is to provide the fifth six-month status report pursuant to Section LV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The attached report provides an update of milestone accomplishments since the overall integrated plan was submitted (Reference 5), including any changes to the compliance method, schedule, or need for relief and the basis, if any.

This letter contains no new regulatory commitments.

If you have any questions regarding this report, please contact Carl B. Corbin at 254-897-0121 or carl.corbin@luminant.com.

I state under penalty of perjury that the foregoing is true and correct.

Executed on August 27, 2015.

Sincerely, Luminant Generation Company LLC Rafael Flores By::__

Vice President Engineering and Support

Attachment:

Comanche Peak Nuclear Power Plant's (CPNPP) Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events c- William M. Dean, Director, Office of Nuclear Reactor Regulation Marc L. Dapas, Region IV Jessica A. Kratchman, NRR/JLD/PMB Balwant K. Singal, NRR Stephen A. Monarque, NRR Resident Inspectors, Comanche Peak Nuclear Power Plant

Attachment to TXX- 15 124 Page 1 of 7 Comanche Peak Nuclear Power Plant's (CPNPP) Fifth Six Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Comanche Peak Nuclear Power Plant (CPNPP) developed an Overall Integrated Plan (Reference 1),

documenting the diverse and flexible strategies (FLEX), in response to Reference 2. This attachment provides an update of milestone accomplishments since submittal of the Overall Integrated Plan and the First, Second, Third and Fourth Six Month Status Reports (References 3, 7, 11 and 12), including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

2 Milestone Accomplishments The following milestone(s) have been completed since the development of the Overall Integrated Plan (Reference 1), and are current as of August 17, 2015.

• FLEX Strategy Evaluation - Complete

• Modifications Evaluations - Complete

• Storage Design Engineering - Complete

• Procedures - PWROG issues NSSS-specific guidelines - Complete

• National Safer Response Center (NSRC) Operational - Complete

• Develop Training Plan - Complete

• Perform Phase 2 Staffing Study -. Complete

• Develop Unit 2 Modifications - Complete

• Develop Site Response Plan with NSRC - Complete 3 Milestone Schedule Status The following table provides an update to Attachment 2 of the Overall Integrated Plan (OIP). It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed. Note, italicized items in the following table were not provided as milestone items in Attachment 2 of the OIP. However, these items are added here for consistency with the 6 month status update template and will be carried forward in future 6 month status updates.

Attachment to TXX-15 124 Page 2 of 7 Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Submit 6 Month Updates:

UpaeIAug 2013 Complete Upae2Feb 2014 Complete Upae3Aug 2014 Complete Upae4Feb 2015 Complete Upae5Aug 2015 Complete FLEX Strategy Evaluation Aug 2013 Complete Walk-throughs or Demonstrations Apr 2015 Started Sep 2015 Perform Phase 2 Staffing Analysis Jun 2014 Complete Jun 2015 Modifications:

Modifications Evaluation Aug 2013 Complete Develop Unit 1 Modifications Mar 2014 Started Sep 2015 Unit 1 Implementation Outage (1RF18) Oct 2014 Not Started May 2016 Develop Unit 2 Modifications Mar 2015 Complete Jul 2015 Unit 2 Implementation Outage (2RF15) Oct 2015 Not Started Storage:

Storage Design Engineering Mar 2014 Complete Storage Implementation Feb 2015 Started Sep 2015' Procure On-Site Equipment Jul12015 Started Sep 2015 Develop Site Response Plan with NSRC Apr 2015 Complete Aug 2015 Install OffiSite Delivery Station (if Necessary) Not Required Not Required Not Required National Safer Response Center Operational Aug 2014 Complete Procedures:

1iW'ROG issues NSSS-speciflc guidelines May 2013 Complete Issue FSGs Aug 2014 Started Oct 2015 Create Maintenance Procedures Jul12014 Started Oct 2015 Training:

Develop Training Plan May 2014 Complete Dec 2014 Implement Training Apr 2015 Started Sep 2015 Full Site FLEX Implementation Oct 2015 Started Apr 2016 Submit Completion Report Feb 2016 Not Started Aug 2016

Attachment to TXX- 15 124 Page 3 of 7 4 Changes to Compliance Method The following are either changes or clarifications to the compliance method and are in addition to those identified in the First, Second, Third and Fourth Six Month Status Reports (References 3, 7, 11 and 12).

Debris Removal On pages 7 and 78 of the OWP, it is implied that debris removal required to deploy FLEX equipment will be completed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of ELAP initiation. However, minimum staffing does not permit debris removal to begin until 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, when limited site access is restored. It is not expected that initiation of debris removal at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> will adversely impact the deployment times associated with successful FLEX strategy implementation. However, validation of FLEX strategies is ongoing and any adverse impacts of initiating debris removal at 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> will be identified and resolved.

Ground Test Well for Phase 2 480V Generator Contrary to page 50 of the OIP, a ground test well will not be installed at the Phase 2 480V generator staging location. Review of the proposed modification determined the ground test well was not required.

Spent Fuel Pool Time to Boil and Associated Actions - Modes 1 through 4 As discussed on page 40 of the OWP, the spent fuel pool (SFP) time to boil value (7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />) was determined using a conservative overestimation of the normal operating decay heat load. The SFP time to boil determination was re-evaluated to arrive at a nominal but still conservative SFP time to boil of 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

The related operator action time to ventilate the Fuel Building and deploy any equipment local to the SFP area necessary for implementation of the backup SFP makeup strategy is therefore revised to 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.

Similarly, the associated duration for SFP boiloff to within 15 feet above the top of the spent fuel racks is 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> (from ELAP initiation), and consequently, the operator action time to initiate SFP makeup is also 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br />. The previous time to boil values and operator response times are discussed on pages 7-8, 40-41, and 78-79 of the OIP.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation In Reference 5, Luminant formally requested relief from the requirement of Section IV.A.2 of the Order (EA-12-049) regarding full implementation no later than two (2) refueling cycles after submittal of the Overall Integrated Plan. NRC approval of the requested relief was received in Reference 8, relaxing full order implementation for Comanche Peak Unit 1 until the completion of the spring 2016 refueling outage.

Full order implementation for Comanche Peak Unit 2 is unchanged and will occur upon completion of the fall 2015 refueling outage. The milestone schedule in Section 3 has been updated for consistency with the approved schedule relief. No additional relief is requested herein.

Attachment to TXX-15124 Page 4 of 7 6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following table provides a summary of the open items documented in the QIP and the status of each item.

Overall Integrated Plan Open Items Status OIl. Finalize location and protection requirements of FLEX Complete. FLEX equipment will be storage buildings. The storage buildings will be stored in a new single structure designed in accordance with the NET guidance and the designed as described in Section 4 of applicable hazards. Reference 7.

012. Perform containment evaluation based on the boundary Complete. The containment analysis conditions described in Section 2 of NET 12-06. Based on concludes no significant heatup or the results of this evaluation, required actions to ensure pressurization of containment as a maintenance of containment integrity and required result of an ELAP when crediting instrument function will be developed as necessary. SHIELD. Per Reference 13, the NRC has reviewed the containment analysis, found no discrepancies and closed the associated confirmatory items noted in Reference 4. No further action required.

013. Development of refueling equipment specifications, Development of final specifications determination of fuel consumption rates, assessment of for all FLEX equipment has started.

fuel supplies and determination of time frames for refueling of FLEX equipment in Phases 2 and 3 will be developed following generation of specifications for FLEX equipment.

014. Finalize FLEX strategies and required modifications Comanche Peak FLEX strategies following resolution of low-leakage RCP seal credit the use of SHIELD low-leakage performance issue. seals as approved in Reference 9.

Preparation of design modifications for installation of SHIELD are in progress.

Attach ment to TXX- 15 124 Page 5 of 7 Draft Safety Evaluation and Interim Staff Evaluation (ISE) are assumed synonymous. The following are additional Open Items documented in the Interim Staff Evaluation (Reference 4). These open items will be carried forward in future 6 month status updates until confirmation is received from the NRC that the items may be closed. Luminant Power is participating in the voluntary NRC audit process described in References 6 and 13.

Interim Staff Evaluation Open Items Status 3.2.1.2.A Regarding the RCP seals, the only 0-ring of interest Reference 9 documents NRC with the safe shutdown low-leakage (SHIELD) installed acceptance of SHIELD for use in is the RCP seal sleeve to shaft 0-ring. Qualification of ELAP evaluations. Luminant has the RCP seal sleeve to shaft 0-ring will be tracked as confirmed the reactor coolant system part of the SHIELD redesign to confirm the delayed pressure and temperature limits of cooldown, as documented in the Integrated Plan, is Reference 9 will be met during an acceptable. CPNPP will align with testing results to be ELAP event at Comanche Peak.

documented in the forthcoming SHIELD white paper. However, per Reference 13, this item remains open pending NRC review of the reactor coolant pump 0-ring material.

3.2.1.2.C If the RCP seals are changed to the newly designed Reference 9 documents NRC Generation 3 SHIELD seals, or non-Westinghouse seals, acceptance of SHIELD for use in the acceptability of the use of the newly designed ELAP evaluations. Item 4 of the Generation 3 SHIELD seals, or non-Westinghouse seals limitations and conditions from should be addressed, and the RCP seal leakages rates for Reference 9 restricts the seal leakage use in the ELAP analysis should be provided with rate to a constant 1.0 gallon per acceptable justification. During the audit process the minute after SHIELD actuation. Any licensee stated that CPNPP uses the Westinghouse deviation from this restriction will be mode193A RCPs crediting SHIELD for FLEX strategies. justified.

Testing and qualification of SHIELD is ongoing and the licensee is closely following the re-design of SHIELD and will modify analyses and FLEX strategies if needed, based on the conclusions of the SHIELD white paper.

3.2.1.8.A The Pressurized Water Reactor Owners Group Per Reference 10, the NRC has (PWROG) submitted to NRC a position paper, dated endorsed the PWROG position paper August 15, 2013 (ADAMS Accession No. ML 13235A with restrictions. Luminant has 132, non-public, proprietary), which provides test data evaluated the impact of these regarding boric acid mixing under single-phase natural restrictions on the CPNPP FLEX circulation conditions and outlines applicability boration strategy and confirmed keff conditions intended to ensure that boric acid addition will be maintained less than 0.99 and mixing would occur under conditions similar to throughout an ELAP event.

those for which boric acid mixing data is available.

However, the NRC staff concluded that the August 15, 2013, position paper was not adequately justified and did not endorse this position paper. As such, ensuring adequate mixing of boric acid into the RCS under ELAP conditions is an open item for CPNPP.

Attachment to TXX-15124 Page 6 of 7 7 Potential Draft Safety Evaluation Impacts Any potential impact to the Interim Staff Evaluation has been previously discussed in Section 4 of this letter.

8 References The following references support the updates to the OJP described in this attachment.

1. Comanche Peak Nuclear Power Plant Docket Nos. 50-445 and 50-446 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049),

dated February 28, 2013.

2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.

3. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, First Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), dated August 28, 2013.

4. NRC Interim Staff Evaluation, "Comanche Peak Nuclear Power Plant, Units 1 And 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF0860 and MF0861)," dated December 19, 2013.

5. Comanche Peak Nuclear Power Plant (CPNPP), Docket Nos. 50-445 and 50-446, Request for Schedule Relaxation for the March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond-Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), dated February 12, 2014.

6. NRC Letter from Jack R. Davis to All Operating Reactor Licensees and Holders of Construction Permits, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigation Strategies Order EA-12-049," August 28, 2013.

7. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Second Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), dated February 27, 2014.

8. NRC Letter from Eric J. Leeds to Mr. Rafael Flores, "Comanche Peak Nuclear Power Plant, Unit 1

- Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," April 14, 2014.

9. NRC Letter from Jack Davis to Mr. James A. Gresham, ADAMS Accession No. ML14132A128, May 28, 2014.

10. NRC Letter from Jack Davis to Mr. Jack Stringfellow, ADAMS Accession No. ML13276A183, January 8, 2014.

Attachmrent to TXX- 15124 Page 7 of 7

11. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Third Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861), dated August 28, 2014.

12. Comanche Peak Nuclear Power Plant, Docket Nos. 50-445 and 50-446, Fourth Six-Month Status Report in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements For Mitigation Strategies For Beyond- Design-Basis External Events (Order Number EA-12-049) (TAC Nos. MF0860 and MF0861)," dated February 26, 2015.

13. NRC Letter from Stephen Monarque to Mr. Rafael Flores, "Comanche Peak Nuclear Power Plant, Units 1 and 2 - Report for the Audit Regarding Implementation of Mitigating Strategies Related to Order EA-12-049 (TAC Nos. MF0860 and MF0861), dated August 5, 2015.